Protecting your privacy

Brisbane Green Heart CitySmart Pty Ltd ACN 099 480 010 (We, Us, Our) is committed to protecting your privacy. In accordance with the Privacy Act 1988 (Cth), this policy outlines how we manage and protect your Personal Information.

To lodge a request or to take part in the Live for Less program, we require Personal Information from you. If you supply us with Personal Information or use our Website, you consent to us collecting, maintaining, using and disclosing your Personal Information in the way described in this Privacy Policy.

Definitions

In this policy:

  • APP means the Australian Privacy Principles under the Privacy Act.
  • CitySmart Partners are the companies and organisations that work with CitySmart in the provision of its programs and services.  Details of the CitySmart Partners are available on the CitySmart website.
  • Personal Information has the meaning given under the Privacy Act.
  • Privacy Act means the Privacy Act 1988 (Cth).
  • Program means the Live for Less program.
  • Program Supporters means the companies working with us to provide the Program and rewards including (without limitation) CitySmart partners.
  • Related Entities has the same meaning as under the Corporations Act 2001 (Cth).
  • Sensitive Information has the same meaning as under the Privacy Act.
  • Services means the Program and the services and rewards offered by us and by companies and individuals who work with us, including the Program Supporters.
  • Website means www.liveforless.com.au or any other website owned, operated, used or controlled by us.

The meaning of any general language is not restricted by any accompanying example and the words ‘includes’, ‘including’, ‘such as’, ‘for example’ or similar words are not words of limitation.

What personal information do we need and collect?

To provide you with our Services or the services of companies and individuals who work with us, we need to collect Personal Information. We also need to collect Personal Information when creating a Live for Less account (also known as ‘joining the movement’) so you can be a participant on our website and access various parts of the Program. Your Personal Information may be used to enable us to identify articles and other information (including information from our Program Supporters) that may be suited to your interests.

Examples of the Personal Information we collect include:

  • your name, email address, postcode and suburb
  • information about your current behaviours around budgeting and money-consciousness;
  • information about your current behaviours around sustainability;
  • any photographs you send us demonstrating you ‘Living for Less’; and
  • any other Personal Information relevant to the Services or the Program.
  • If we do not collect the Personal Information or if any of the Personal Information you provide is incomplete or inaccurate, we may not be able to provide the Services or those Services may be compromised.

How do we collect the Personal Information?

We aim to collect Personal Information directly from you.  This may occur:

  • when you send an email or other communication to us;
  • if you contact us or a Program Supporter;
  • when you complete a form in respect to the Program;
  • when you log onto our website. Our server automatically records information your browser sends when it connects to a website. This may include your Internet Protocol (IP) address and your browser type and language. We may also collect information about your usage (for example, by way of cookies) including when you use our website, other sites you access from our website, content upload and download, your usage of the services available on our website and the other website users you connect with through our website;
    when you provide information by using any downloading facilities on our website.

We also collect Personal Information:

  • from third parties, for example, a member of your family, household or a friend who includes information about you in a Living for Less article, blog or photograph;
  • through our website and by other electronic communication channels;
  • when we are required to do so by law;
  • from our own records.

If at any time you supply Personal Information to us about any other person (e.g. another member of your household or a friend), you represent and we accept that information on the basis that you are authorised to do so and that the relevant person has consented to the disclosure to us.

How do we use your Personal Information?

We use the Personal Information we collect to:

  • provide our Services;
  • process your inquiries and improve our Services;
  • advise you of articles, additional services or information which may be of interest to you;
  • publish articles, blogs and information on Living for Less, including contributions from contributors;
  • provide your contact details to Program Supporters to enable them to provide the rewards or other services to you;
  • develop existing and new rewards, products and services; and
    maintain and update our business infrastructure and systems.

Disclosing Personal Information

Unless we are required to provide your Personal Information to others by law, by court order or to investigate suspected fraud or other unlawful activity, your Personal Information will only be seen or used by employees, contractors and Program Supporters who are assisting us to provide the Services.

We restrict the Personal Information we disclose to our Program Supporters to that which each of them needs to provide their respective services.  Personal Information will be de-identified when demographic data (e.g. community averaging data such as the age and gender of participants and their interests and suburbs with the most Live for Less participants) is provided to our Program Supporters.

We may also disclose your Personal Information to third parties in certain circumstances including:

  • if you agree to the disclosure;
  • in circumstances where you would reasonably be expected to consent to information of that kind being passed to a third party;
  • where disclosure is required or permitted by law;
  • where it is required to be disclosed for audit purposes;
  • if disclosure will prevent or lessen a serious or imminent threat to someone’s life or health; or
  • where it is reasonably necessary for the enforcement of the criminal law, a law imposing a pecuniary penalty or for the protection of public revenue.

Considerations when you send information to us

While we do all we reasonably can to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including investing in security software, no data transfer over the Internet is 100% secure.

The open nature of the Internet is such that information exchanged via the Internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including (without limitation) Personal Information, it is sent at your own risk.

If you provide Personal Information to us electronically, there are steps you can take to help maintain the information’s privacy. These include:

  • always closing your browser when you have finished your session;
  • NEVER providing Personal Information by using a public computer; and
  • NEVER disclosing your user name and password to another person.

You are responsible for all actions taken using your username, email or password. If at any time you believe your username or password has been compromised, immediately contact us and also change your password.

How your information is stored

We endeavour to keep our information systems and files secured from unauthorised access and our employees, contractors and individuals and companies who assist us to provide Services are aware of the importance we place on protecting your privacy and their role in helping us to do so.

Our procedures to securely store Personal Information include electronic and physical security measures, staff training and use of password protection software.

While we store the majority of the personal information that we collect from you in Australia, from time to time we utilise Cloud services (including storage services).  Our current Cloud service provider’s server is located in the United States. Personal Information in the United States or any country other than Australia is not covered under the APPs and will be subject to the laws of that country.  An overseas recipient may also be subject to a foreign law which could compel disclosure of personal information to a third party, for example, an overseas government or regulatory authority.

CitySmart takes steps to ensure the overseas recipients with whom we deal are companies of repute.  However, CitySmart has no control over how the overseas recipient deals with your Personal Information or whether they comply with the APPs.  If the overseas recipient does not comply, you will not be able to seek redress from CitySmart or the overseas recipient under the Privacy Act and may not be able to seek redress in the overseas jurisdiction.  If you do not consent to this, please do not provide Personal Information. If you require any further information at any time, please contact our Privacy Officer, whose details are set out below.

When the Personal Information that we collect is no longer required, we will remove or de-identify the Personal Information as soon as reasonably possible. We may, however, retain Personal Information for as long as is necessary to comply with any applicable law, for the prevention of fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies owed and to resolve disputes.

Marketing and opting out

We do not use Sensitive Information for marketing purposes.If at any time you no longer wish to receive any additional marketing material from us or do not want your information disclosed for direct marketing purposes, contact our Privacy Officer and we will remove your details from our marketing database.

If at any time you no longer wish to receive any additional marketing material from us or do not want your information disclosed for direct marketing purposes, contact our Privacy Officer and we will remove your details from our marketing database.

How long do we keep your Personal Information?

We do not keep your Personal Information for any particular period of time, unless we are required to keep your information for a particular period of time by law.

How you can update, correct, or delete your Personal Information

You may request access to your Personal Information or correct any inaccurate or out of date information by clicking here or contacting our Privacy Officer using the details below.

You may request the source of any information we collect from a third party. We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld. If there is a reason under the Privacy Act or other law for us not to provide you with information, we will give you a written notice of refusal setting out the reasons for the refusal except to the extent it would be unreasonable to do so and the mechanisms available to you to complain about the refusal.

Changes to our privacy policy

This document sets out our current Privacy Policy. Our Privacy Policy will be updated from time to time. You should review our Privacy Policy each time you visit our Website or provide us with Personal Information.

This document sets out our current Privacy Policy. Our Privacy Policy will be updated from time to time. You should review our Privacy Policy each time you visit our Website or provide us with Personal Information.

How to complain if you believe we have  breached the Australian Privacy Principles

If you believe that we have dealt with your personal information in a way that is inconsistent with the APPs, you should contact our Privacy Officer in the first instance using the details below.  If we are unable to resolve your complaint you may contact the Office of the Australian Information Commissioner, whose details are also set out below.

Contacting us

Our Privacy Officer is contactable at:

You should also contact our Privacy Officer:

  • immediately if you believe someone has gained access to your Personal Information;
  • immediately if you believe we have breached our privacy obligations or your privacy rights in any way; or
  • would like to discuss any issues about our privacy policy.

More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the Office of the Australian Information Commissioner by:

  • website – www.oaic.gov.au
  • mail – GPO Box 5218 Sydney NSW 2001
  • email – enquiries@oaic.gov.au

Current as of 14.4.16